N.N. Bhagwati vs Commissioner Of Income-Tax

The Supreme Court indicated that the judgment in H.H. Sir Rama Varma v. CIT [1994] 205 ITR 433 requires reconsideration by a larger bench, particularly regarding the interpretation of Sections 80A and 80AB of the Income-tax Act, 1961. The court noted that both sections were introduced simultaneously, with Section 80A having retrospective effect from April 1, 1968, and questioned the applicability of the Board's circulars stating Section 80AB was prospective. The appeal was dismissed as it was covered by the earlier judgment, with no costs awarded.